PRIVACY POLICIES
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01PRIVACY POLICIES [includes cookies, spam and
personal information]
In connection with your use of the Services, we may collect, store, use, share, and/or process certain information about you and your interaction with our Services. For further explanation on how we treat information collected and received from you when you use the Services and/or participate in our Online and/or blended learning courses, please see our Privacy Policy. At Counshelp Management Consultancies Co LLC (“COUNSHELP”, “we”, “us”, “our”) we respect your privacy rights. We have created this privacy policy (“Privacy Policy”) to explain how we treat the information collected and received from your use of our Services (as defined in our Terms of Use or “YOU”) provided through the website, www.alphacosec.com and www.counshelp.legal any other websites or applications we own, operate, or control (the “Website(s)”). This Privacy Policy applies only to the Services, and we are not responsible for the practices of persons, companies, institutions, or websites that COUNSHELP does not control, manage, or employ. Capitalized terms not defined herein have the meanings set forth in the YOU. Please read this Privacy Policy as well as our YOU carefully, as they govern your use of COUNSHELP.
If you do not agree to this Privacy Policy, please do not use our Services. COUNSHELP is the data controller of your information. Please see the “Contact Information” section below for additional details. Please note that if you obtain access through Sponsored Services or our Employee and Enterprise Sponsored Access Services, the third party sponsoring your participation in the Online Courses may provide us information subject to our agreement with them and therefore the third-party sponsor may be the controller for such data.
COUNSHELP respects and is committed to protecting your privacy.
Background
This website is owned and operated by COUNSHELP, hereafter referred to as Company.
Policy limitations
This policy is limited to information collected the Company from marketing activities and through this website. This website may contain links to other websites that are not controlled by or related to the Company. The Company is not responsible for these sites, their content, their omissions, or the policies and practices engaged in by their owners and/or operators. We recommend that you read the privacy policies of these sites before deciding your personal information to the site operators. Our hyperlinks are not to be construed as an endorsement of any other website.
Consent
The choice is always yours whether or not to provide personal information to the Company. Any personal information you provide will be treated with utmost care and subject to this policy, will not be used or disclosed by the Company in ways to which you have not consented. You may opt out of certain uses and disclosures of your personal information, as explained below. By submitting your personal information to us, you signify your consent to the Company, its instructors, affiliates and business partners’ collection, use, and disclosure of this information by this policy. By using our website, you also consent to the collection and use of anonymous information as discussed below.
Personal information collected by the company
The company collects information in several ways. When you register for a course available with us, we may ask for contact information such as your name, address, telephone number and e-mail address, and for billing information. We may also ask you to complete certain forms or surveys that gather information about you, your academic background, business, profession, job and your opinions or comments. Correspondence sent to us by you or by third parties about your activities, including letters or emails, may be collected into a file specific to you.
Non-identifiable information
Non-identifiable information is sometimes collected from visits to our website. In general, anyone can visit our website without telling us who he/she is or revealing any information about business or personal needs. Unless you complete an online form, our web servers collect anonymous, non-identifiable information about you such as the Internet Protocol (IP) address of your computer, the IP address of your Internet service provider, the date and time you access our website, the Internet address of the website from which you may have linked to our website, the operating system you are using, the sections or areas of our website that you visit, the website pages read and images viewed, and the content you download from our website, but not the e-mail addresses of visitors. Our website logs IP addresses and browser information for purposes of system administration, identifying technical difficulties, evaluating traffic patterns and usage of our website, and otherwise providing content relevant to visitors to our website. It may be aggregated to measure certain information, including, without limitation, the number of visits, average time spent on our web site, and related user practices. In general, we will use this information to measure the use of and to improve our website and the benefits that you can get from using our website. This non-identifiable information may also be disclosed to others and permanently archived for future use.
Cookies and other technology
A technology called “cookies” may be used to provide you with tailored information and to help personalize and enhance your experience with our website. A cookie is a tiny element of data that a website can send to your browser, which may be stored on your hard drive (not on our website), and is used to recognize you as a previous user of our website, to offer personalized web page content and information for your use, to track your activity at our website so that we may better respond to your needs. Some cookies are “session cookies,” meaning that they are deleted shortly after the end of a session. You are always free to decline our cookies if your browser permits, although in that case, you may not be able to use certain features on our website or engage in transactions through our website.
Anti-Spam Policy
We do not email unless someone has filled out an opt-in form or opt-out form expressing an interest in our information or products and/or services, or otherwise directly and proactively requesting it. News of the features and benefits of Membership is spread through advertising, joint venture marketing, and word of mouth, so we are only building relationships with others who wish to learn more about what we have to offer and willingly subscribe to our content and contact through email. You are always completely in control of whether you receive email communication from COUNSHELP, and can terminate at any time. Emails and Prohibited Content Email messages sent in connection with the survey tool, will contain an “unsubscribe” link that allows our subscribers to remove themselves from the email messages. We acknowledge and agree that we will not hide, disable, or remove or attempt to hide, disable, or remove the opt-out link from the email invitation. We will actively manage and process unsubscribe requests received by us directly within ten days of submission, and update your email lists and address books to reflect the unsubscribe requests. You are responsible for ensuring that during use of the Survey Tool your email messages do not generate serveral spam complaints over industry standards. If we determine that your level of spam complaints is higher than industry standards, we, at our sole discretion, have the right to terminate your use of its Survey Tool. Permission Lists has a zero-tolerance spam policy. We follow all local and international SPAM laws and regulations.
Use of personal information
Your personal information is intended to be used only by the administrator, members of Company and the others specified below to provide programs and services, to respond to requests, to verify contact information, to provide account information, course pricing and other related information, to improve our offerings and to generally support your use of our services and our website. Personal information we collect may be used to enhance the benefits that you receive from Company in the following ways: Provide our services to you Confirm credit-worthiness Confirm your registration and orders Respond to your service enquiries or requests Communicate special offers to you, if you chose to receive such notices Enhance our website operation and efficiency Inform you by email, fax or mail of Company’s courses, upcoming events or other items you may find interesting.
Opting-out
At any time you may ask us to stop sending you email or mail by contacting us by email at [email protected] From time to time, however, we may send to you email or mail containing important information regarding our services or our website, which we are required to deliver. You may not opt out of receiving these communications. In general, we use information in the file we maintain about you and your profile to evaluate current and past activities, to resolve disputes and to troubleshoot problems. After a reasonable period of time consistent with our records retention and destruction policies, we will destroy or make anonymous any of your personal information that is no longer needed to fulfil the purpose for which it was collected. Use, disclosure, and transfer of personal data Personal information about our clients is an important part of Company’s business, and we are not in the business of selling that personal information to others. We share client information only with the parties described below:
1. Disclosure to agents and suppliers. We may use third party agents, suppliers and service providers to facilitate the provision of our programs, and services. For example, we may outsource the operations of one or more aspects of our website to a supplier or service provider who performs services according to our requirements. In some instances, the service provider may collect information directly from you (such as the situation where we ask a service provider to conduct a survey or contest for us). In order to provide certain services, we must disclose some of your personal information to certain service providers, such as our associates, or to a processing or authorization company to charge you for the services. Since we want to service your specific needs, we encourage our associates in business to follow privacy practices no less protective of all users than the practices we describe in this policy.
2. Disclosure to affiliates. We may provide your personal information to affiliates of Company. They may use your personal information to provide you with email or other information about their products and services and other matters. In the event we share your personal information with any affiliates and subsidiaries, they will have agreed with us to protect the privacy of your personal information in a manner that is consistent with this policy. If at any time you do not wish us to make any further disclosure of your personal information to any affiliates and subsidiaries, please notify us at _____________
3. Disclosure to business partners. We may provide your personal information to certain companies with which we have developed a business relationship and which we believe can be of service to you. Before personal information is disclosed, the recipient organization will agree with us to protect the privacy of your personal information in a manner that is consistent with this policy. Recipient organizations may use your personal information to provide you with email or other information about their products and services and other matters. If at any time you do not wish us to make any further disclosure of your personal information to such organizations, please notify us at [email protected]
4. Disclosure in business transfers. We may sell or transfer some or all of Company or merge with another entity. As part of that transaction, we may disclose your personal information to the other entity, but will require the entity to agree to protect the privacy of your personal information in a manner that is consistent with this policy.
5. Law enforcement and legal disclosure. We may disclose your personal information (a) to a government institution that has asserted its lawful authority to obtain the information, (b) where we have reasonable grounds to believe the information could be useful in the investigation of unlawful activity (c) where we have reasonable grounds to believe that disclosing such information is necessary to identify, contact, or bring legal action against someone who may be violating a contract with us or violating the terms of use of our website or may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other Centre clients, or anyone else that could be harmed by such activities, (d) to comply with legislation, or (e) to comply with a warrant or an order made by a court, person or body with jurisdiction to compel the production of information, or to comply with court rules regarding the production of records and information. We may disclose your personal information to our legal counsel, auditors, and consultants to permit them to perform professional services for us.
Data integrity and security When you provide personal data to us through our website in any manner, such data is stored on secured servers that are protected by this Policy. To help protect the confidentiality of your personal information, we employ security safeguards appropriate to the sensitivity of the information. We will strive to protect your personal information, but Company cannot warrant the security of any information you transmit to us and you do so at your own risk. Please keep in mind that whenever you voluntarily disclose personal information on-line that information can be collected and used by others.
Changes to the Privacy Policy
Company reserves the right to change this Policy from time to time and in its sole discretion. Any amendments we make to this Policy will apply to your personal information from the time we post the amendment on our website. For your convenience, the date of the last update to this policy is listed below. It is your responsibility to regularly check our website for amendments to this Policy. You agree to be bound by amendments when posted on our website.
Important Information About Using Our Services
Please understand that by submitting any information to us, you acknowledge that we may collect, use, disclose and retain such information in accordance with this Privacy Policy and our TOU, and as permitted or required by law. If you do not agree with these terms, then please do not provide any information to us. COUNSHELP may offer social sharing features as part of its Services which, among other features, allows you to make your careers Profile (as described below in Profiles and Career Services Section) public as well as sharing your details and information, including your Online Course progress with others outside of the COUNSHELP Website(s) (“Social Sharing”). By electing to participate in any of our Social Sharing Services, you acknowledge that any information or materials you include in your Profile can be viewed by other persons accessing the Website(s), including potential or existing employers, as well as by others on applicable third-party websites. You also acknowledge that information you share through Social Services may remain accessible on third party websites and/or to those you have shared the information with in the event you make your Profile private after having made it public and/or ceasing to share your information and that COUNSHELP has no control over the access of or use of information provided to third parties via Social Sharing outside its Website(s).
What Information We Collect
Information You Provide Us We collect a variety of information that you provide directly to us. In general, we collect information from you through:
• Using any of our Services, including registering for a User Account through the Website(s)
• Making a purchase from us, including registering and enrolling in any Online Course
• Signing up for email updates
• Uploading or posting to public forums included through the Services
• Submitting requests or questions to us via forms or email
• Requesting customer support and technical assistance
The types of data we collect directly from you include:
• Name, address, telephone number and email address
• Log-in credentials, if you register a User Account with us
• Information about purchases or other transactions with us, such as your shipping address. Please note, however, that we do not collect, store, or transmit financial account information. Instead, we use a third-party payment processor to process our payments • Information about your customer service and maintenance interactions with us
• Demographic information, such as your gender, socio-economic status, and other personal information
• Information you provide to us in connection with any application or admissions process, including, for example, educational and work experience, prerequisite knowledge, any pre-assessment you complete, your goals, and other information
• Information you provide in connection with career services, for example, salary information, job placement information, career goals, work experience, and other information
• User-generated content you upload or post to public forums through the Services. Information needed in order to comply with any procedures, laws, and regulations which apply to us where it is necessary for our legitimate interests or the legitimate interests of others
• Information from third parties about you in connection with any referral programs we may offer
• Any other information you choose to directly provide to us in connection with your use of the Services Participation in Online Courses. If you desire to participate in an Online / blended Course, you will be asked to provide us with certain information necessary to conduct such an Online / blended Course.
This information may include, among other things, your name and email address. COUNSHELP, or its third-party service providers, may also collect certain information from you in conjunction with assignments, exams and other assessments related to the Online / blended Course. For example, as part of a proctored exam for an Online / blended Course or to process your credential of completion for a said program, COUNSHELP (or its third-party service providers, may collect certain information from you in order to
verify or authenticate your identity or submissions made by you, such as a signature for a test or assignment log, a photograph or recording of you (e.g., using a webcam) or information included on a government issued or other photo identification card or document, or (b) monitor your performance during an exam to confirm that you are abiding by the applicable test rules or requirements (e.g., confirming that you are not using prohibited resources).
COUNSHELP may also collect information from you or about your performance or accomplishments related to the course, such as quiz/exam scores, grades, project evaluations, teacher evaluations and other evaluations of your performance or accomplishments. Profiles and Career Services. You can choose to share additional information, such as your work experience, resume and transcript, your picture, and answers to questions about your experience, studies and work preferences, when you create a professional profile through the career services we offer through our Services. You can also share information by updating your Profile, uploading documents, or answering questions or surveys we email you or present to you through our Services. Collectively, the professional profile and the materials you provide through the career services are referred to as simply your “Profile.” Please note, that by electing to make your Profile public, you acknowledge that:
• Your Profile and all the included information, materials, documents and pictures will be shared with, and publicly viewed by, other third parties also accessing the career services portal and the Services (including without limitation, potential employers, recruiters, other students or persons, and us);
• Employers and other third parties accessing the career services portal can contact you via your email address (or any other contact information you have provided in your Profile); and
• You and We can share your Profile and all the included information, materials, documents and pictures with employers, recruiters or career related third parties.
Referral Programs
We may offer certain Users the opportunity to refer (Referrers) their friends (“Referees”) to the Site through a third-party referral program whereby both Referrers and Referees may obtain credits or other rewards through such referrals. To the extent we offer such programs, the Referrers may share information about the Referees, including email addresses for the purpose of sharing the referral offer. We may also share the Referrer’s email and name with the Referee as well as provide the Referrer the confirmation of the Referee’s acceptance of the referral which may include Referee’s email in connection with providing any such referral program. How We Use The Information We Collect We use your information for various purposes depending on the types of information we have collected from and about you and the specific services you use, in order to:
• Send you information in connection with the Services
• Respond to your communications and requests
• Manage and process Online /Blended Courses, including but not limited to tracking attendance, progress and completion; administering exams, projects, and other assessments; verifying a User’s identity as part of a proctored exam or exit interview for an Online / blended Course; and monitoring performance during an exam to confirm that you are abiding by the applicable testing rules or requirements
• Provide Services to you, such as services that you request in conjunction with the Online / blended Courses
• Contact you by email, postal mail, or phone (including via SMS messages) regarding COUNSHELP and third-party products, services, surveys, research studies, promotions, special events and other subjects that we think may be of interest to you
• Customize the content we provide through the Services
• Help us better understand your interests and needs, and improve the Services
• Engage in analysis, research, and reports regarding use of the Services
• Secure the Services
• Comply with any procedures, laws, and regulations which apply to us where it is necessary for our legitimate interests or the legitimate interests of others
• Establish, exercise, or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others
Combined Information
For the purposes discussed in this Privacy Policy, we may combine the information that we collect through the Services with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Privacy Policy. Aggregate/Anonymous Data We may aggregate and/or anonymize any information collected through the Website so that such information can no longer be linked to you or your device (“Aggregate/Anonymous Information”). We may use Aggregate/Anonymous Information for any purpose, including without limitation for research and marketing purposes, statistical analyses of Website(s) usage, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors.
How We Share and Disclose Your Information
COUNSHELP will share your information in the following ways: • Service Providers. We provide access to or share your information with operations and maintenance contractors and other third parties who perform services on our behalf. They have access to perform these services but are prohibited from using your information for other purposes. They provide a variety of services to us, including billing, sales, marketing, test proctoring, product content and features, advertising, analytics, research, customer service, data storage, security, fraud prevention, payment processing, and legal services.
• Employers. We may share the information that we collect from you when you participate in an Online / blended Course if the course is sponsored or paid for by your employer. For example, we may share with your employer pre-assessment results, the Online / blended Courses you are interested in, your progress in the course, including project status, time spent actively involved in or with an Online / blended Course or interacting with your Mentor, and/or evaluations and performance assessments. If you make your Profile public on the Website, and your employer has access to the Website, then your employer will have the ability to view your Profile information and materials. This information may be shared at any time during the course or afterwards.
• Educational Institutions and Scholarship Partners. If you are taking a course sponsored or associated with a particular Educational Partner (e.g., such as a university or scholarship/sponsored partner), we may share information about you and your performance with the university or scholarship partner, including to report on your progress in the course. Information shared with our Educational Partners will be subject to the privacy policies and procedures of such partners.
• Business Partners. With your consent, COUNSHELP may share information that can be used to directly connect you with third party business partners, such as companies that may be offering products or services or other opportunities that may be of interest to you.
• Protection of COUNSHELP and Others. By using the Website, you acknowledge and agree that we may access, retain and disclose the information we collect and maintain about you if required to do so by law or in a good faith belief that such access, retention or disclosure is reasonably necessary to: (a) comply with legal process (e.g. a subpoena or court order) or law; (b) enforce our Terms of Use, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; (d) respond to your requests for customer service; and/or (e) protect the rights, property or personal safety of COUNSHELP, its agents and affiliates, its users and/or the public. This includes exchanging information with other companies and organizations for fraud protection, compliance with applicable law, and spam/malware prevention, and similar purposes.
• Profiles and Career Services. If you make your Profile public, your information will be publicly accessible and further share with our network of hiring partners, including, without limitation, performance in online courses, demographic information (such gender), details of your Profile and other information related to your work experience and goals.
• Related Entities and Affiliates. We may share information with our affiliated companies that are under the common ownership or control of COUNSHELP.
• Business Transfers. As we continue to develop our business, we may buy, merge, or partner with other companies. In such transactions, (including in contemplation of such transactions) user information may be among the transferred assets. If a portion or all of COUNSHELP’s assets are sold or transferred to a third-party, customer information (including your email address) would likely be one of the transferred business assets. If such transfer is subject to additional mandatory restrictions under applicable laws, COUNSHELP will comply with such restrictions.
• Aggregate/Anonymous Information. From time to time, COUNSHELP may share Aggregate/Anonymous Information about use of the Services, such as, but not limited to, publishing a report on usage trends or survey results, as well graduation rates, careers studies and success rates, and other demographic information provided to us by our Students. The sharing of such data is unrestricted.
Retention of Your Information
We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws.
Children's Privacy
COUNSHELP is intended for general audiences and not for children under the age of 18. If we become aware that we have inadvertently collected “personal information” from children under the age of 18 without legally- valid parental consent, we will take reasonable steps to delete it as soon as possible. We also comply with other age restrictions and requirements in accordance with applicable local laws.
International Users
COUNSHELP stores information about visitors to our Website and users on servers located in India. By using our services, you consent to the storage of your information inside the India. If you are using the services from outside India, please know the information you submit will be transferred to and stored in servers in India or other countries. The data protection and other laws of India and/or other countries might not be as comprehensive as those in your country. By submitting your data and/or using our services, you acknowledge the transfer, storing, and processing of your information in and to India. As described above, COUNSHELP also may subcontract the processing of your data to, or otherwise share your data with, service providers and others in countries other than your country of residence, including India, in accordance by applicable law. Such third parties may be engaged in, among other things, the provision of services to you, the processing of transactions, and/or the provision of support services. By providing us with your information, you acknowledge any such transfer, storage or use. If we provide any information about you to any such entities, we will take appropriate measures to ensure such companies protect your information adequately by this Privacy Policy. If applicable, you may make a complaint to the data protection supervisory authority in the country where you are based. Alternatively, you may seek a remedy through local courts if you believe your rights have been breached.
How We Protect Your Information
We consider the confidentiality and security of your information to be of the utmost importance. COUNSHELP takes a variety of technical, administrative, and physical measures to protect your information from disclosure to or access by third parties. Please note that we do not guarantee the security of information, as no method of internet transmission or storage is completely secure. Also note that we may retain and store your information in our databases and systems even after your COUNSHELP account is deactivated as long as we have a legitimate purpose to do so and in accordance with applicable law.
Changes To Our Privacy Policy
Please note that we review our privacy practices from time to time and that these practices are subject to change. Any change, update, or modification will be effective immediately upon posting on our Website(s). You can know if the Privacy Policy has changed since the last time you reviewed it by checking the “Effective Date” included at the beginning of the document. If we make a material change to the Policy, you will be provided with appropriate notice by legal requirements. By continuing to use the Services, you are confirming that you have read and understood the latest version of this Privacy Policy. Be sure to return to this page periodically to ensure familiarity with the most current version of this Privacy Policy.
International Policies
COUNSHELP stores information about its students and users on servers located in India or other countries. If you are using our services from outside India, please be aware that the information you submit will be transferred to and stored in servers in India and/or other countries. The data protection and other laws of the India and/or other countries might not be as comprehensive as those in your country. By submitting your data and using our services, you consent to the transfer, storing, and processing of your data in and to India or elsewhere.
COUNSHELP Contact Information
If you have any questions, comments, or complaints about this Privacy Policy or about how the company manages personal data, please contact us: [email protected]